United States Sixth Circuit

The district court did not have subject-matter jurisdiction to hear a "direct taxation" claim not raised during the administrative process. The distinction between physical injury and non-physical injury, for purposes of calculating gross income under the Tax Code, 26 U.S.C. section 104(a)(2), does not violate equal protection.

Appellate Information

• Argued 03/25/2003
• Decided 06/17/2003
• Published 06/17/2003

Judges

• Before DAUGHTREY and GIBBONS, Circuit Judges;  MILLS, District Judge.

Court

• United States Sixth Circuit

Counsel

• For Appellant:
  
• Philip C. Kimball (argued and briefed), Louisville, KY, for Appellant.


• For Appellees:
  
• Kenneth L. Greene (argued and briefed), Michael J. Haungs (briefed), United States Department of Justice, Washington, D.C., for Appellee.